In this issue: IRS Reverses its Position on Closing a Forward with Borrowed Stock; Equity Units Exchange Offer; Repurchase Premiums and Consent Fees; Reporting Obligations for Corporate Actions Continued; Withholding on ADR Fees; Repeal of Expanded Form 1099 Information Reporting Requirement; Another Derivium Capital Case; Proposed Regulations for COD Income Exceptions; Press Corner; MoFo in the News; and FrankNDodd.
In this first issue of our fourth volume of Tax Talk, we cover a flurry of capital markets guidance recently issued by the Internal Revenue Service (“IRS”). In particular, the IRS issued a chief counsel advice addressing whether variable prepaid forward contracts treated as open transactions can remain open if settled with borrowed securities. The IRS also issued a private letter ruling to a corporate taxpayer that wanted to repurchase outstanding equity units. Another IRS private letter ruling addressed the federal income tax treatment of repurchase premium and consent fees paid in connection with the repurchase and modification of certain debt. The IRS also released a generic legal advice memorandum (“GLAM”) about withholding on ADR fees. Finally, our regular features – Press Corner and MoFo in the News – are also included.
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